APPENDIX 1X - EB-2018-0056 COST OF SERVICE RATE APPLICATION

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APPENDIX 1X - EB-2018-0056 COST OF SERVICE RATE APPLICATION
APPENDIX

                   1X

COST OF SERVICE
RATE APPLICATION
EB-2018-0056
APPENDIX 1X - EB-2018-0056 COST OF SERVICE RATE APPLICATION
APPENDIX 1X - EB-2018-0056 COST OF SERVICE RATE APPLICATION
APPENDIX 1X - EB-2018-0056 COST OF SERVICE RATE APPLICATION
APPENDIX 1X - EB-2018-0056 COST OF SERVICE RATE APPLICATION
APPENDIX

                   1Y

COST OF SERVICE
RATE APPLICATION
EB-2018-0056
Niagara-on-the-Lake Hydro Inc.
                 EB-2018-0056 | Business Plan
                            Filed: August 2018

Exhibit 1
Business Plan
Niagara-on-the-Lake Hydro Inc.
                                                                                                         EB-2018-0056| Business Plan
                                                                                                                           Page 1 of 36
                                                                                                                    Filed: August 2018

     Table of Contents
 1   1. Mission and Values ....................................................................................... 4
 2        Mission................................................................................................................................ 4
 3        Values ................................................................................................................................. 4
 4        Principles ............................................................................................................................ 4
 5        Tactical Initiatives ................................................................................................................ 6
 6   2. About the Utility........................................................................................... 11
 7        Utility Description .............................................................................................................. 11
 8        Corporate Structure of the Utility ....................................................................................... 11
 9   3. Economic Overview and Customer Description ...................................... 13
10        Economic Overview of the Service Area ........................................................................... 13
11        Customer Description........................................................................................................ 13
12   4. Outcomes of the Renewed Regulatory Framework ................................. 15
13        Customer Focus ................................................................................................................ 15
14        Seeking Customer Input .................................................................................................... 15
15        Alignment of Goals to Needs and Preference of Customers.............................................. 16
16        Public Policy Responsiveness ........................................................................................... 17
17        Financial Performance ...................................................................................................... 17
18   5. Performance Metrics and Future Plans .................................................... 19
19        PEG Performance ............................................................................................................. 19
20        Rates ................................................................................................................................ 20
21        Revenues .......................................................................................................................... 26
22        Capital Spending ............................................................................................................... 27
23        Operational Costs ............................................................................................................. 33
24        Personnel.......................................................................................................................... 34
25        Financial Performance ...................................................................................................... 36
26

27
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 1   Executive Summary
 2   This business plan for Niagara-on-the-Lake Hydro Inc. (“NOTL Hydro”) has been structured to
 3   provide a comprehensive review of the key aspects of NOTL Hydro’s business and to review the
 4   key initiatives for the next five years that are currently contemplated.
 5
 6   The key aspects of NOTL Hydro reviewed include:
 7      1. Mission, values and Principles
 8      2. A general description of the company
 9      3. A general description of its market and the Town in which it operates
10      4. The regulatory environment
11      5. Key performance indicators and Future Plans

12
13   The key initiatives over the next five years include:
14               Keeping Rates Low – Despite being the smallest LDC in the Niagara region, NOTL
15               Hydro has had the lowest rates in the region for the past few years. In 2014-2017,
16               NOTL Hydro had the lowest rates across all three major rate classes. In 2018, NOTL
17               Hydro had the lowest residential and GS>50 kW rates and the second lowest GS
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 1   Reliability – Reliability was rated by our customers as their top priority. NOTL Hydro
 2   has achieved low outage rates over the past few years. However, this can be due to
 3   luck as much as to good planning. NOTL Hydro will continue to make investments
 4   with the goal of continually improving reliability. These investments include the
 5   ongoing voltage conversion program which replaces the oldest assets and makes the
 6   system a more consistent voltage as well as the investments in switches and
 7   reclosures.
 8
 9   Planning for the Future – NOTL Hydro believes that it will be its responsibility to
10   allow its customers to have the choice as to whether they wish to install renewable
11   generation or battery storage. NOTL Hydro will continue to make investments, where
12   economically prudent, that facilitate this choice. The investments in switches and the
13   battery storage project are examples of this.
14
15   Sound Management – None of the above initiatives can be achieved unless NOTL
16   Hydro has the basics in place. These include good governance, a motivated and
17   experienced staff, sound financial management, good and steady profitability and
18   continued investments. NOTL Hydro will continue to operate in a sound business
19   manner.
20
Niagara-on-the-Lake Hydro Inc.
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 1   1. Mission and Values
 2   Niagara-on-the-Lake Hydro Inc. (“NOTL Hydro”) is a fully licensed distributor of electricity
 3   pursuant to a distribution license ED-2002-0547 issued by the Ontario Energy Board (the “OEB,
 4   Board”) under the Ontario Energy Board Act, 1998 (the “Act”).
 5
6    The utility develops and manages a monopoly electrical distribution network in the Town of
7    Niagara-on-the-Lake and delivers electricity to residential and commercial customers via its
8    distribution system. NOTL Hydro earns income based on fixed and volumetric charges for the
9    distribution of this electricity as well as service charges for related services. The charges or rates
10   are set through a periodic rate making process via applications to the OEB.

11   Mission
12   Niagara-on-the-Lake Hydro is a trusted partner for our customers. Niagara-on-the-Lake Hydro
13   will continuously seek to provide low cost energy delivery, high reliability and high power quality.

14   Values
15   We will perform our Mission while maintaining the following values:
16      1. No compromise on safety and health
17      2. Operate with integrity in all our dealings
18      3. Anticipate and meet the needs of our customers
19      4. Build value for our shareholder
20      5. Develop and maintain a strong team of employees
21      6. Be financially prudent
22      7. Enhance the environment

23   Principles
24   The following principles have been driving our investment decisions for the past couple of years
25   and will continue to do so. It is recognized that there is an inherent contradiction between many
26   of these principles and managing is about finding a balance between them. These are not
27   necessarily in an order:
28
29      1. The distribution grid will be needed. The local grid will be an integral part of the future
30          electricity system so we should continue to keep it in the best shape possible.
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 1   2. Our role is to allow customer choice. Customers should be free to choose to make their
 2      own energy related decisions or leave them to us. We should not be engaged in activities
 3      designed to enrich ourselves at the expense of giving customers choice. Instead, we
 4      should be looking at investments that promote customer choice. Implicit in all this is the
 5      continued trade-off between cost and customer service (choice) that will always make
 6      decisions difficult. The trade-off between providing more distributed generation capacity
 7      and the cost of energy storage is an example of this. The trade-off between controlled and
 8      uncontrolled electric vehicle charging is another.
 9   3. We should always strive to be a cost-conscious operator. Having lower costs means
10      always having the flexibility to make investments when needed without these becoming a
11      rate or burden issue.
12   4. We should make our system as flexible as possible. We do not know what the future
13      demands will be on our system but the more flexible it is the more likely it can respond to
14      these demands. The current investments in automated switches and reclosures are an
15      example of this. Increasing our transformation capacity is another example.
16   5. We do not have to do it all ourselves. Many of the new technologies will be beyond the
17      scope of NOTL Hydro (integrated customer contact systems) but can still be provided
18      through joint purchasing (CHEC) or through third party providers. Other services will be
19      best provided in-house.
20   6. Electricity is a utility. The vast majority of customers want to have power when they
21      need it (all the time), to have a reasonable bill and to otherwise be left alone. Our job is
22      not to reach out to customers but to be there when customers want to reach out to us and
23      to anticipate their needs.
24   7. Being municipally owned provides a distinct advantage. Because our customers are
25      also our shareholders we can make decisions based on the aggregate benefit to them.
26      This may mean decisions that are better for them as customers rather than shareholders.
27      Private ownership may not have this option.
28   8. NOTL Hydro should continue to be run independently and as a profit-making
29      business. This provides the discipline to manage costs and the freedom to make long-
30      term decisions.
31   9. We should hire the best employees possible and have the best working
32      environment. Motivated and intelligent employees will always provide the best service
33      and, in the long run, at the lowest cost.
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1       10. NOTL Hydro will continue to advocate on behalf of its customers when NOTL Hydro
2           believes this is in the customer’s best interest. Advocacy will always be about what is
3           best for our customers; not what is best for NOTL Hydro.

4

 5   Tactical Initiatives
 6   NOTL Hydro plans on achieving its strategic goals by engaging in the following tactical initiatives:
 7
 8               Customer Communications
 9               We recognize that most of our customers expect electricity to be provided 100% of
10               the time, expect a monthly bill delivered on a timely and accurate basis and do not
11               expect to communicate with us otherwise. However, if our customers do wish to
12               communicate with us they expect this to be as simple and effective as possible. To
13               achieve this, we maintain as many lines of communication as possible such as an
14               open office, phone lines, e-mail, twitter, Town Councillors, etc. We will also provide
15               readily available material which we believe to be relevant should our customers wish
16               to access it.
17
18               NOTL Hydro manages its own CDM programs so that relationships have been
19               developed between NOTL Hydro staff and the larger commercial customers. NOTL
20               Hydro was awarded the Energy Star Utility of the Year – Regional for 2014 by Natural
21               Resources Canada in recognition of these efforts. NOTL Hydro is the smallest utility
22               to have received this award.

23

24               Advocacy
25               We are not just a distributor of electricity to our customers. We are their
26               representative to the electricity sector as a whole. If we believe decisions are being
27               made that are not in the best interests of our customers we will advocate on their
28               behalf.

29
30               Rate Management
31               An LDC has many opportunities to make decisions that have a rate impact.
32               Examples include the timing of capital investments, the choice between operating
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 1   or capital expenditures in addressing issues and capitalization policies. NOTL Hydro
 2   has deliberately made decisions that are neutral or have a lower rate impact. Over
 3   a decade and a half the impact has been considerable.

 4   A more significant example of this has been our investment in transformer stations.
 5   These investments increase our distribution rates as these significant investments
 6   are added to rate base. However, this rate increase is more than offset by the
 7   reduction in transmission rates for our customers.

 8

 9   Strategic Alliances
10   There is a vast pool of people with experience, knowledge and expertise in the electric
11   industry within the province, including the fraternity between utilities, partnerships with
12   private consultants in many disciplines and contacts with venders supplying the latest
13   technologically advanced products for all distribution companies and customers. All
14   the above is tapped through associations, partnerships (both informal and formal, for
15   profit and not for profit corporations), forums and working groups. Working collectively
16   and collaboratively, they can share ideas and resources, solve problems, adapt to
17   new regulations and policy changes from governing bodies. NOTL Hydro and its
18   employees are members of the following associations, partnerships, and groups:
19             • Cornerstone Hydro Electric Concepts (CHEC)
20             • Utility Collaborative Services (USC)
21             • Utilities Standards Forum (USF)
22             • Financial Executives International (FEI)
23             • Professional Engineers of Ontario (PEO)
24             • Chartered Professional Accountants (CPA) Ontario
25
26   NOTL Hydro also participates in groups on an ad hoc basis such as regional utilities
27   meetings, Southwest conservation group, and Grid Smart City.

28
29   Invest in our People
30   We invest and retain our quality people by making their experience at NOTL
31   Hydro positive, safe and progressive. We offer continuous opportunities for
32   training and personal development; we keep our staff informed and promote a
33   culture of customer satisfaction. We make the changes necessary to promote a
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1    positive work environment. The result of this strategy is an engaged workforce
2    and a low turnover.
3

4    Capitalize on Technology
5    NOTL Hydro keeps abreast of changing technologies through ongoing
6    discussions with vendors and other LDCs. When these technologies make sense
7    from a cost and performance perspective NOTL Hydro will invest. In 2010, NOTL
8    Hydro was one of the first Ontario LDCs to invest in automatic switches. These
9    switches, which have direct communication links between themselves and with
10   the TS stations, will automatically switch feeds if there is a power outage in the
11   Olde Town. Prior to the implementation of these switches, the Olde Town, which
12   is at the end of the feeder lines, had a poor outage performance and this was a
13   source of concern and frustration with our customers. Customers now comment
14   on how much better the outage performance is.
15
16   NOTL Hydro is currently investing in more switches and re-closures to continue
17   to reduce outages and to expand the flexibility of our system in anticipation of
18   future demands in this regard. These investments also expand the capability of
19   our SCADA system.
20
21   In 2015, NOTL Hydro went live with its new outage management system. This
22   system utilizes the last gasp of the smart meters to provide alerts to line crews
23   and senior management of outages. Like many LDCs, NOTL Hydro now has
24   stories of restoring lost power during the night before customers were even aware
25   they had an outage.
26
27   The battery storage project with the Smart Grid Fund and Panasonic is another
28   example of investing in new technologies. NOTL Hydro sees energy storage as a
29   tool which will allow its customers greater choice as to whether they invest in
30   distributed generation. This project will help demonstrate that use of the battery
31   technology.
32
33
34
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1    Plan for the Future
2    While NOTL Hydro does not know what the future will bring, it tries to invest and
3    align its practices according to its best estimates. A current example is the growth
4    in distributed generation. NOTL has one of, if not the highest, density of solar
5    installations in Ontario. Eventually, these will begin to have an impact on the
6    performance of the distribution lines. NOTL Hydro is monitoring this closely. One
7    investment we are making is in additional switches and reclosures which will
8    eventually facilitate changing the flow of electricity within the NOTL Hydro grid.

9    We are also looking for opportunities to invest in energy storage which will
10   facilitate allowing more solar installations. NOTL Hydro was recently awarded a
11   Smart Grid Fund contract which will contribute to an investment in a 250 kW/ 250
12   kWh lithium-ion battery which will be installed on one of NOTL Hydro’s feeders.
13   The objective of this project will be to assess the ability to use the battery to
14   increase the capacity for renewable energy on the feeder.
15
16
17   Continuous Emphasis on Safety
18   Safety must always be the primary priority at an LDC. NOTL Hydro continues to
19   stress the importance of safety in all its activities. In 2012, NOTL Hydro was
20   awarded the ZeroQuest Sustainability level award for safety; the first LDC in
21   Ontario to reach this level.
22
23   For the past three years, NOTL Hydro has hired a part time specialist dedicated
24   to safety who helps ensure NOTL Hydro is kept abreast of best practices and
25   helps ensure the continuous emphasis on safety. In 2018, NOTL Hydro hired an
26   independent consultant to perform a safety audit on the company.
27
28
29   Financial Prudence
30   NOTL Hydro believes it is prudent to maintain a low debt:equity level. The gives
31   the company the financial flexibility to make investments or pay dividends when
32   needed. The current low debt:equity level reflects the effect of this strategy. The
33   two increases in 2005 and 2015 were the result of significant investments in the
34   high voltage transformer stations.
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1
2                         Table 1: Historic Debt:Equity Ratios

                                 NOTL Hydro Debt:Equity Ratio
     1.60

     1.40

     1.20

     1.00

     0.80

     0.60

     0.40

     0.20

     0.00
            2004   2005   2006   2007   2008   2009   2010   2011   2012    2013   2014   2015   2016

                                        NOTL Hydro           Ontario LDCs
3
4   Note: Debt is comprised of current and long-term debt and notes to related
5   parties. For 2006-2008 Ontario LDC debt does not include current portion
6
7
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 1   2. About the Utility

 2   Utility Description
 3   NOTL Hydro has been in existence for over 100 years. Hydro-electric commissions were originally
 4   formed in 1912 in the original Olde Town of Niagara (previously Newark) as well as in Queenston.
 5   These were merged in 1970 when the Town of Niagara and the Township of Niagara merged to
 6   create the present boundaries. In 1983 the assets of Ontario Hydro in the Town were purchased
 7   so that the Commission served the entire population. In the early 2000’s the NOTL Transmission
 8   Station was purchased from Hydro One and the York Transmission Station was built. Both of
 9   these Transmission Stations are supplied by Hydro One 115 kV transmission lines so NOTL
10   Hydro does not rely on Hydro One for any high voltage transformation. NOTL Hydro employs 18
11   full time highly trained staff and is an active partner in the community.
12

13   Corporate Structure of the Utility
14   NOTL Hydro is 100% owned by the Town of Niagara-on-the-Lake through the holding company
15   Niagara-on-the-Lake Energy Inc.
16                                       Table 2: Corporate Structure

17
18
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1   Table 3: Organizational Chart
2

3

4
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 1   3. Economic Overview and Customer Description

 2   Economic Overview of the Service Area
 3   The Town of Niagara-on-the-Lake is known across Canada and around the world as a tourism
 4   and agricultural centre. The Town receives over 1.5 million tourists a year visiting the Shaw
 5   Festival, Fort George, the wineries and the Olde Town. Business is thus dominated by services
 6   (retail, accommodation, entertainment) and agriculture (wineries, greenhouses, farms). The Town
 7   also hosts one of the campuses of Niagara College. There is next to no manufacturing industry.
 8
9    The Town of Niagara-on-the-Lake has a population of 17,500 and this is expected to grow to
10   22,400 by 2031 according to Town forecasts. The Town is known as a retirement community and
11   the average age in the Town is above the provincial average.
12

13   Customer Description
14   NOTL Hydro’s customer makeup by customer category as of December 31, 2017 is as follows:
15
16                             Table 4: Customer Count December 31, 2017
         Customer Category                                            Count
         Residential                                                  7,913
         General Service (50kW)                                      127
         Unmetered & streetlights                                     29
         Total                                                        9,406
17
18   Like most LDC’s, NOTL Hydro has seen an ongoing decline in average customer usage due to
19   conservation, more efficient equipment and, for residential, declining household sizes. The trend
20   is not as pronounced in the general service classes due to movements between classes and
21   growth at individual customers. Streetlight consumption is declining due to the switch to LED
22   lights.

23
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1                       Table 5: Average Monthly Consumption per Customer
    Customer Category              2014     2015     2016     2017        2018       2019
    Residential                    810      793      793      753         775        761
    General Service (50kW)        53,180   54,976   55,696   53,974      54,821     52,739
    Streetlights   &   Unmetered
                                   57       48       40       44          43         41
    Load
2

3
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1    4. Outcomes of the Renewed Regulatory Framework
2    On October 18, 2012, the Ontario Energy Board (“The Board”) issued its “Report of the Board: A
3    Renewed Regulatory Framework for Electricity Distributors: A Performance Based Approach”.
4    The report set out a comprehensive performance-based approach for the Renewed Regulatory
5    Framework which promotes the achievement of outcomes that would;
6                 •   benefit existing and future customers;
7                 •   align customer and distributor interests;
8                 •   continue to support the achievement of important public policy objectives; and
9                 •   place a greater focus on delivering value for money.
10
11   On March 5, 2014, the Board issued its report on “Performance Measurement for Electricity
12   Distributors: A Scorecard Approach”. The report set out the Board’s policies on the measures that
13   are to be used to assess a distributor’s effectiveness and improvement in achieving customer
14   focus, operational effectiveness, public policy responsiveness, and financial performance to the
15   benefit of existing and future customers.
16
17   With the above in mind, the next section provides an account of how NOTL Hydro continues to
18   improve in its understanding of the needs and expectations of its customers and its delivery of
19   services.
20

21   Customer Focus
22   NOTL Hydro values customer input and feedback. Customers are engaged through education
23   opportunities, surveys and directly by the utility for input on key initiatives. Customer satisfaction
24   is measured on the Distributor Scorecard as well as a bi-annual survey and is incorporated into
25   goal setting and the planning processes, with a focus on ensuring and improving customer
26   satisfaction.
27

28   Seeking Customer Input
29   NOTL Hydro is 100% owned by the Town of Niagara-on-the-Lake so it is ultimately owned by its
30   customers. Customers therefore not only have a say in the operation of the business but a stake
31   in it as well.
32
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 1   Customers will contact NOTL Hydro directly with concerns or questions. It is recognized that these
 2   usually relate to issues that affect them directly (bills, services or capital work on or near their
 3   property) but customers do reach out on general industry topics as well.
 4
 5   The next commonly used channel of customer input is through the Board of Directors. All current
 6   Directors are residents of NOTL and have regular communication with customers. Customers will
 7   also contact their municipal Councillor. All Councillors have lines of communication with NOTL
 8   Hydro management.
 9
10   In advance of its 2019 Cost of Service, NOTL Hydro opened several lines of communication with
11   its customers to get specific feedback on the utility’s proposed capital and operational budget.
12   These included open house meetings, open questions on our website, bill inserts and dedicated
13   meetings with some of our largest customers.
14

15   Alignment of Goals to Needs and Preference of Customers
16   NOTL Hydro strives to address our customers’ preferences and priorities and believe our goals
17   are in synch with theirs. As part of its 2018 Open Houses, NOTL Hydro asked customers to rank
18   selected priorities with a range of 1-7. The following is the result of that survey:
19
20               Priority 1) Reliability – Score 1.64
21               NOTL Hydro has had reliability scores better than the provincial average (excluding
22               Hydro One) for the past three years. NOTL Hydro will continue to invest in smart grid
23               technology to improve its reliability.
24
25               Priority 2) Lowest Rates – Score 1.94
26               NOTL Hydro has the lowest residential rates in the Niagara Region.
27
28               Priority 3) Service – Score 3.36
29               As a locally owned utility, NOTL Hydro is focussed on providing local service.
30
31
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 1              Priority 4) Investment – Score 3.79
 2              NOTL Hydro maintains an annual investment program designed to continually
 3              improve the overall system.
 4
 5              Priority 5) Conservation – Score 3.97
 6              NOTL Hydro expects to meet its entire 2015-2020 conservation obligation in 2018.
 7
 8              Priority 6) Generation – Score 4.36
9               NOTL Hydro’s goal is to allow all customers that want renewable generation to be
10              able to install renewable generation.
11
12              Priority 7) Underground – Score 5.15
13              NOTL Hydro has a multi-decade plan to convert the Olde Town to underground to
14              improve safety and reliability.
15

16   Public Policy Responsiveness
17   NOTL Hydro believes that the current state of the electricity sector is grounded through public
18   policy that ensures the sustainability of generation, transmission and distribution, while
19   considering economic and environmental consequences. NOTL Hydro is doing its part by
20   responsibly upgrading and maintaining its distribution system in stride with the useful life of the
21   infrastructure and growth of the community in an efficient manner at reasonable cost. NOTL
22   Hydro’s DSP is used as a tool to ensure the schedule for these activities are planned effectively
23   and a balanced approach to spending is continued in to the foreseeable future. NOTL Hydro is
24   particularly proud of our continued low outage and duration of outage statistics that corroborate
25   our effectiveness at managing the distribution system. In recent years, public policy has driven
26   environmental improvements in the sector by means of the LDC’s Conservation and Demand
27   Management obligations. NOTL Hydro’s CDM program is extremely effective in reducing electric
28   usage in our service territory and we are ranked 12th in the Province as of July 15, 2018.
29

30   Financial Performance
31   NOTL Hydro continues to record solid financial performance metrics. Key factors to this financial
32   success are effective business planning, a continuous focus on operational efficiency, and
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1   managing capital and expense expenditures to budget. The Business Plan and DSP will serve an
2   important role in providing the future direction of financial expenditure and performance.
3
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 1   5. Performance Metrics and Future Plans
 2   There is no single metric to measure performance. Low rates or costs are a good measure but
 3   not if they are at the expense of good service and system investments. Likewise, financial
 4   performance is a good measure but not if at the expense of high rates. NOTL Hydro’s approach
 5   is to consistently measure itself across as many measures and benchmarks as possible
 6   recognizing that an LDC cannot be the best at everything but can be good across all measures.
 7
 8   The following section reviews various measures of performance and, where appropriate, provides
 9   the goals for future performance. These include:
10           1. PEG Performance
11           2. Distribution Rates
12           3. Revenues
13           4. Capital Spending
14           5. Operational Costs
15           6. Personnel
16           7. Financial Performance
17

18   PEG Performance
19   Perhaps the most widely-known benchmark of efficiency rating comes from the PEG report which
20   surveys utilities in Ontario. The PEG analysis is one of the few instruments that compares utilities’
21   cost efficiencies on a consistent basis and is publicly available. PEG produces an annual report
22   that provides a ranking of the utilities included in the study, summarizes the results, and provides
23   insight into the trends in utility efficiency scoring.
24
25   The PEG past performance table below shows NOTL Hydro’s rating for the last 6 historical years
26   of business. The PEG report uses econometrics to determine the cost efficiency of distributors.
27   Since the new categories were created in 2013, NOTL Hydro has consistently been in group three
28   with an associated stretch factor value of three. Group 1 (of 5) is ranked as the most efficient
29   group. As seen below, NOTL Hydro has achieved a consistent rating.
30
31
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 1                                 Table 6: PEG Past Performance (Stretch Factor)
                                                            2013        2014         2015        2016
      Stretch Factor Cohort - Annual Result                 3           3            3           3
      Associated Stretch Factor Value                       0.30        0.30         0.30        0.30
 2
 3   The percentage difference between actual and predicted cost is the measure of cost performance.
4    A negative performance means that actual costs are lower than predicted costs. NOTL Hydro’s
5    performance has improved in this regard over the past six years.
6
 7                                 Table 7: Summary of Cost Performance Results
                                   2011       2012        2013         2014         2015         2016

      Actual Total Cost                                   $6,036,142   $6,125,368   $6,362,425   $6,619,352

      Percentage Change on
                                                                       2.0%         3.8%         4.0%
      Previous Year
      Percentage      Difference
      (Cost Performance) per       6.5%       2.7%        -0.7%        -2.8%        -6.6%        -6.4%
      PEG Analysis
 8
 9   NOTL Hydro’s performance is the result of operating in accordance with its values rather than
10   with the specific objective of improving its PEG rating. The performance does indicate that its core
11   values are aligned with those envisioned in the PEG methodology. It is hoped that this
12   performance improvement will continue over the next five years with the continued application of
13   NOTL Hydro’s values and that NOTL Hydro may even move into the Group 2 stretch cohort.
14   However, NOTL Hydro understands that some actions, such as increasing the number of
15   employees to maintain service levels, may have a negative impact on the PEG performance in
16   the short term.
17

18   Rates
19   NOTL Hydro’s strives to have the lowest delivery rates in the Niagara Region across all the major
20   rate classes. NOTL Hydro focusses on delivery rates rather than just distribution rates as a
21   distributor is able to affect the other components of delivery rates including transmission rates,
22   loss factors and rate riders. In this regard it has been successful from 2014-2017 though in 2018
23   its small business customer rate was second lowest.

24
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1                             Table 8: Niagara Region Residential Delivery Charges

              Niagara Region Residential Delivery Charge (with # customers)
    $70.00                           - May 1, 2018
                                                                                                      1,307,544
               Line losses      Transmission   Distribution

    $60.00

                                                                                          28,808
    $50.00
                                                                           1,307,544
                             244,114     11,169       22,853     53,617
    $40.00   9,234

    $30.00

    $20.00

    $10.00

       $-
              NOTL       Alectra - St.    Grimsby      Welland     NPEI    Hydro One -    Canadian     Hydro One -
                         Catharines                                       Thorold Urban Niagara Power Thorold Rural
2

3
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1                             Table 9: Niagara Region Small Business Delivery Charges

                           Niagara Region Small Business Delivery Charge (with #
    $200.00
                                                customers)
                                              - May 1, 2018
    $180.00                                                                                                    1,307,544

    $160.00

    $140.00

    $120.00                                                                          1,307,544     28,808
                                                                           11,169
    $100.00                                                244,114
                                 9,234      53,617
                  22,853
     $80.00

     $60.00

     $40.00

     $20.00

        $-
                   Welland         NOTL        NPEI        Alectra - St.   Grimsby   Hydro One -   Canadian   Hydro One -
                                                           Catharines                 Thorold       Niagara    Thorold
             Line losses     Transmission   Distribution
                                                                                       Urban        Power      General
2

3

4

5
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1                       Table 10: Niagara Region Large Business Delivery Charges

                   Niagara Region Large Business Delivery Charge (with #
                                        customers)
    $14,000.00
                                      - May 1, 2018
                                                                                                          1,307,544

    $12,000.00

    $10,000.00
                                                                                  1,307,544      28,808

     $8,000.00

                                                                       11,169
                                        244,114          22,853
     $6,000.00               53,617

                 9,234
     $4,000.00

     $2,000.00

           $-
                 NOTL         NPEI      Alectra - St.    Welland       Grimsby     Hydro One -   Canadian   Hydro One -
                                        Catharines                                  Thorold      Niagara     Thorold
                                      Line losses       Transmission    Distribution Urban        Power      General
2
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 1                              Table 11: Residential Bill Impacts (Distribution Only)
                                                                                               2019
              Year                       2014      2015      2016          2017      2018
                                                                                               (proposed)

                                         Including Rate Riders
              Monthly Charge             19.21     18.96     21.70         24.66     27.27     30.88
              Volumetric                 0.0104    0.0127    0.0059        0.0045    -0.0001   -0.0001
              Total (750 kwh)            $27.01    $28.49    $26.13        $28.04    $27.20    30.81
              Bill Impact                          5.46%     -8.30%        7.29%     -3.01%    13.27%

                                         Excluding Rate Riders (incl. IRM & SME charge)

              Monthly Charge             18.73     18.96     21.85         24.81     27.43     30.81
              Volumetric                 0.0126    0.0135    0.0105        0.0073    0.0040    -
              Total                      $28.18    $29.09    $29.73        $30.29    $30.43    30.81
              Bill Impact                          3.21%     2.18%         1.87%     0.46%     1.25%
 2
 3   Generally, bill impacts are subject to a modest increase during the IRM years – in NOTL Hydro’s
 4   case from 2014 to 2018. It is important to note that bill impacts also include the effects of the
 5   disposition of deferral and variance accounts from pass-through charge (regulatory assets).
 6   These substantially increase the volatility of rates from year to year.
 7
 8   The rates NOTL Hydro has applied for in 2019 continue the trend of maintaining low rates. NOTL
 9   Hydro is looking for a modest increase in rates after incorporating the ICM rate rider into base
10   distribution rates. NOTL Hydro is seeking an increase in revenue of $50k compared to what NOTL
11   Hydro would have earned given current rates. Due to changes in the way streetlighting rates are
12   calculated, other classes will see a bigger rate increase as per the following table:
13                      Table 12: Change in Revenue Requirement by Customer Class

                                                                 Change in
                                            Customer Class        Revenue

                                            Residential          $    34,748
                                            GS50                $     9,009
                                            Unmetered            $        77
                                            Streetlights         $   (57,832)
                                            Large User           $    53,622
14                                                               $    50,399
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 1   Delivery rates are affected by more than just the revenue requirement of the distributor. Other
 2   factors include rate riders as discussed above, transmission rates and the loss factor.
 3
 4   NOTL Hydro tries to keep its rate riders as close to zero as possible. It has been making changes
 5   to its billing process to enhance this goal. The rate riders proposed for 2019 are close to this
 6   objective. However, in 2018, NOTL Hydro had rate riders that were credits and reduced the cost
 7   to our customers. The switch from credit rate riders to one that has a small increase in rates
 8   creates a more substantial increase in rates.
 9
10   Due to its ownership of its transmission stations, NOTL Hydro has one of the lowest transmission
11   rates in the Province. Its transformation charge in the Line Connection Charge is zero. Due to a
12   cool summer in 2017, NOTL Hydro’s transmission rates are declining based on its rate application
13   for 2019.
14
15   NOTL Hydro’s line loss rate is one of the lowest in the Province and, at 3.79%, is tied for the
16   lowest in the Niagara Region with Alectra in St. Catharines. NOTL Hydro is applying to lower its
17   line loss rate to 3.73%.
18
19                                 Table 13: Bill Impact Summary – Segmented Impact
     Bill Segment                       Residential       GS < 50       GS > 50          USL    Streetlights       Large User

     Distribution Rates plus ICM    $         0.38    $     0.60    $     5.71    $     0.63    $   (669.04)   $    4,468.66
     Rate Riders                    $         1.00    $     3.20    $   228.68    $    (0.41)   $     62.71    $    8,354.73
     Line losses                    $        (0.04)   $    (0.10)   $    (3.59)   $    (0.04)   $     (0.53)   $     (132.86)
     Transmission                   $        (0.32)   $    (0.84)   $   (18.93)   $    (0.33)   $     (3.08)   $     (965.50)
                                    $         1.01    $     2.86    $   211.87    $    (0.15)   $   (609.94)   $   11,725.03
20                                           0.97%         1.10%         3.01%        -0.14%        -14.45%            4.59%

21   When all these factors are combined the net impact on our various customer classes is
22   summarized in the table above.
23
24   With little movement in rates sought for 2019, NOTL Hydro expects its rates will continue to be
25   the lowest in the Niagara region and one of the lowest in Ontario. NOTL Hydro plans to continue
26   to operate in a prudent manner so that this rate performance continues.
27

28
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1    Revenues
2    NOTL Hydro’s revenues are historically steady and changes in revenues are a combination of
3    customer growth and changes in rates excluding rate riders.
4
5                                       Table 14: Historical and Proposed Revenues
                                    2014          2015          2016          2017          2018          2019
      Residential    Fixed          17.94         18.17         21.06         24.02         26.86         30.24
                     Variable       0.0126        0.0128        0.0098        0.0066        0.0033        -
                     Cust/Conn      7,230         7,551         7,772         7,913         7,976         8,152
                     kWh            69,164,029    70,322,391    72,859,329    70,851,537    73,760,865    73,998,981
                      Revenues      $2,381,359    $2,483,926    $2,597,709    $2,731,715    $2,814,235    $2,958,334

      GS50          Fixed          266.42        269.88        274.74        279.14        281.65        281.65
                     Variable       2.1025        2.1298        2.1681        2.2028        2.2226        2.6132
                     Cust/Conn      133           121           129           127           131           131
                     kWh            81,046,957    83,783,451    83,544,376    82,904,820    85,961,669    82,705,771
                      Revenues      $842,669      $818,758      $835,662      $876,154      $934,564      $988,010

      Large User     Fixed                                                                                $4,538.81
                     Variable                                                                             2.6132
                     Cust/Conn                                                                            1
                     kWh                                                                                  23,308,825
                      Revenues                                                                            $177,656

      USL            Fixed          20.05         20.31         20.68         21.01         21.20         20.15
                     Variable       0.0060        0.0061        0.0062        0.0063        0.0064        0.0085
                     Cust/Conn      22            19            16            28            26            26
                     kWh            237,520       245,994       178,578       273,288       251,508       251,508
                      Revenues      $12,312       $5,395        $2,134        $7,674        $8,224        $8,426

      Streetlights   Fixed          7.42          7.52          7.66          7.78          7.85          6.87
                     Variable       29.0338       29.4112       29.9406       30.4196       30.6943       17.7609
                     Connections    2,080         2,098         2,126         2,126         2,155         2,187
                     kWh            1,160,024     979,421       850,570       858,869       873,782       886,616
                      Revenues      $245,028      $267,284      $260,761      $271,284      $281,864      $224,121

      Other          Other          $425,893      $309,649      $521,351      $353,310      $333,386      $502,939
      revenue        revenue

      TOTAL          Cust/Conn      8,695         9,028         9,261         9,406         9,469         9,649
                     kWh            190,793,158   197,043,769   200,239,261   195,611,162   203,154,504   223,029,214
                     Revenues       $4,970,288    $5,002,950    $5,332,265    $5,337,666    $5,502,840    $6,047,363

                     Distribution   $523          $520          $519          $530          $546          $575
                     Revenues
                     per Cust
6
7
8
9
10
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 1   NOTL Hydro’s longer term performance in reducing distribution revenues per customer can be
 2   seen in the table below. This ties in with the goal of keeping rates lower. Some of the increase
 3   from 2016 to 2019 comes from the 2015 ICM rate riders which in 2019 will become distribution
4    revenue. The new large user will also drive up revenues per customer with high revenues
5    coming from only one customer.
 6
 7                               Table 15: Historical and Proposed Revenues

 8
 9
10   NOTL Hydro expects that revenue will continue to grow at a steady level over the next years as
11   new customers are added. The revenue growth will continue to be driven primarily by customer
12   growth as rates increase largely just with inflation.
13

14   Capital Spending
15   NOTL Hydro believes capital spending should be largely consistent from year to year. This
16   consistency is needed to ensure that NOTL Hydro distribution grid is maintained over the long
17   term and to maintain fiscal discipline. It is recognized that there will be variations from year to
18   year due to customer requirements and due to the lumpiness of certain projects like new TS
19   transformers.
20
21   NOTL Hydro’s Distribution System Plan as provided in its 2014 Cost of Service Application laid
22   out NOTL Hydro’s philosophy towards capital spending. These align with the requirements of the
23   Ontario Energy Board Consolidated Distribution System Plan and include meeting the immediate
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1    needs of customers for new or expanded access (System Access), maintaining a sufficient and
2    stable asset replacement program (System Replacement), planning for the future including
3    investing in smart grid technologies (System Service) and maintaining adequate support systems
4    (General Plant). These background drivers coupled with the condition of field assets formed the
5    basis for determining priority spending for specific projects. This information is in turn used in
6    further considerations through engagement with all partners/stakeholders (see below) involved in
7    the planning process.
8
9               •     Customers
10              •     the Regional and Municipal Governments
11              •     CDM Program Partners
12              •     IESO
13              •     the Transmission Company – Hydro One
14
15   NOTL Hydro places a high priority on balancing its obligations to accommodate growth while
16   addressing the upkeep and replacement of its infrastructure.
17
18                                 Table 16: Historical Capital Additions
                                       2014          2015           2016             2017
              System Access            1,335,187     1,142,488      1,140,579        1,110,764
              System Renewal           1,004,902     639,645        1,025,066        770,255

              System Service           26,201        121,282        182,663          218,817
              General Plant            114,769       67,072         107,532          267,554
              Total recurring          2,481,059     1,970,487      2,455,837        2,367,390

              Transformer (ICM)        375,965       2,059,240      28,781           -
              Total                    2,857,024     4,029,727      2,484,618        2,367,390

19
20   System access capital are primarily expenditures to connect new customers or update customer
21   connections. It also includes pole relocations for third parties. The expenditures provided are
22   before any customer or third party contributions. These are charged according to our Conditions
23   of Service and the Ontario Energy Board economic evaluation model.
24
25   System renewal capital are expenditures to replace existing assets and ensure the overall system
26   is maintained appropriately. The annual projects are determined by the voltage conversion plan
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1    and, going forward, by the asset management plan. Annual expenditures are determined based
2    on a combination of resource availability and the need to insure that over time annual
3    expenditures are sufficient to replace aging stock. This is estimated by adjusting the annual
4    depreciation of poles, conduit and transformers for inflation.
5
 6                               Table 17: Depreciation vs. System Renewal ($000’s)
                                      2014            2015            2016             2017
            Depreciation              $564            $574            $590             $600
            Inflation adjustment      143%            144%            144%             144%
            Required expenditure      $806            $827            $850             $864
            Actual expenditure        $1,005          $640            $1,025           $770
            Variance                  $199            ($187)          $175             ($94)
 7
 8
9    System service capital are expenditures to improve the operating capabilities of the NOTL Hydro
10   distribution grid. The replacement of the transformer at NOTL MTS is a system service
11   expenditure but has been shown separately due to its size and that it was approved through an
12   ICM application. The increase in system service expenditures is the result of upgrades to the
13   SCADA system and increased investments in automated switches to reduce outage times and
14   improve the flexibility of the system.
15
16   General plant capital are expenditures for the supporting infrastructure needed to operate the
17   distribution business including software upgrades, building improvements, general capital
18   supplies and rolling stock. A big expenditure in 2017 is the purchase of a new truck to replace
19   one that has reached end of life. The total cost of $343k is being spread over 2017 and 2018.
20
21   The utility’s Rate Base has increased proportionally to its capital investments and as such has
22   remained historically as stable as has its other financial metrics.
23
24
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1                                   Table 18: Future Capital Additions ($000’s)
                   2018     2019        2020     2021     2022    2023     2024       2025    2026    2027
     System
                   1,808    835         851      842      854     873      885        897     910     927
     Access
     System
                   1,052    1,097       1,160    935      935     969      1,002      1,010   1,020   999
     Renewal
     System
                   85       85          98       100      130     106      170        142     175     140
     Service
     General
                   313      84          72       149      134     535      51         82      454     121
     Plant
     Total
                   3,258    2,101       2,181    2,026    2,053   2,483    2,108      2,131   2,559   2,187
     recurring

     Battery                442
     Transformer   -        3,250       -        -        -       -        -          -       -       -
     Total         3,258    5,793       5,181    2,026    2,053   2,483    2,108      2,131   2,559   2,187

2
3
4   The following are the key assumptions and planned expenditures included in the above table:
5           •    The high system access expenditure in 2018 is the result of the installation of a new
6                feeder line for a customer and the movement of a pole line along Lakeshore Rd. for
7                the Region of Niagara.
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 1   •   System access expenditures beyond 2018 are expected to be lower than in the recent
 2       past due to lower growth. Growth will be more by infill rather than new subdivisions.
 3       As this is driven by customer demand, this is subject to change.
 4   •   System renewal expenditures will be maintained at a fairly constant level in line with
 5       past expenditures and in line with deprecation adjusted for inflation. These
 6       expenditures are necessary to maintain a healthy system. Over time the focus of the
 7       investments will switch from primarily voltage conversions to being a mix of voltage
 8       conversions and replacements of individual assets (poles, transformers) based on the
 9       asset management system.
10   •   System service expenditures will grow over time due to the development of a smarter
11       grid with investments in more automated switches, more reclosures, voltage regulators
12       and an upgrade in the SCADA. These investments will make the NOTL Hydro grid
13       more resilient and better prepared for the increased demands made on it in the future
14       as customers invest in distributed energy.
15   •   The System Service expenditure is higher by $442K in 2019 due to the investment in
16       the battery, a Smart Grid Fund deployment project in which NOTL Hydro will install a
17       250 kW / 250 kWh lithium-ion battery on one of its feeders and analyze how the battery
18       can be used to increase the capacity of this feeder line for installed renewable
19       generation.
20   •   Beyond the battery, the forecast does not include any expenditures on energy storage
21       or other solutions to address the challenge of having too much distributed generation.
22       This is a growing issue in NOTL as there is significant and growing investment in
23       distributed energy by customers and three feeders are already at capacity. There is
24       currently not sufficient information to forecast the best investments to address this
25       issue and their respective cost.
26   •   The major general plant investments include new line trucks in 2018, 2023 and 2026,
27       major software upgrades every five years and work on the building in 2023.
28   •   The new transformer is to replace the second aged transformer at the NOTL TS. The
29       first transformer was replaced in 2016 when one of the old 25 MVA transformers was
30       replaced with a 50 MVA transformer. In this project planned for completion in 2019, a
31       83 MVA transformer will replace the existing 41.7 MVA transformer at York TS and the
32       41.7 MVA transformer will be moved to NOTL TS to replace the second 25 MVA
33       transformer. This will provide NOTL Hydro with capacity at both stations to serve the
34       entire NOTL load; providing valuable redundancy. This project has been accelerated
35       due to ongoing problems with the second 25 MVA transformer at NOTL MTS.
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 1
 2   The impact of NOTL Hydro’s long-term capital program can be seen in the chart below. Net fixed
 3   assets will remain at their current level in 2017 and 2018 but make a substantial increase in 2019
4    with the addition of the new transformer.
5
 6                               Chart 19: Net Fixed Assets per Customer

 7
 8
9
10   The key objectives of the capital investment program proposed by NOTL Hydro for the next five
11   to 10 years include:
12          •   Ensuring customer needs for supply system security and reliability are met through
13              implementation of cost effective solutions, by mitigating the risk of asset failures in
14              service, and through economically efficient investments;
15          •   Mitigating and reducing the public safety risks from distribution system operations;
16          •   Meeting NOTL Hydro’s regulatory obligations to customer service, including the
17              obligation to serve customers within the service territory and the obligation to relocate
18              lines when requested by the Regional and Municipal Governments, in conjunction with
19              road widening programs and compliance with Measurement Canada regulations
20              related retail revenue metering;
21
22          •   Providing access to connect green energy generation to distribution system through
23              Smart grid development initiatives, improving protection, controls and monitoring of
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 1                    distribution stations and effective use of data provided by smart meters for energy
 2                    conservation and demand management; and
 3                •   Improving worker safety and productivity and enhancing operating efficiency.
 4
 5   More detail on all the forecast capital investments can be found in NOTL Hydro’s DSP.
 6

 7   Operational Costs
 8   NOTL Hydro continually reviews its business and operational goals against; its workforce needs,
 9   its financial strength and the impact on its customers. NOTL Hydro recognizes the importance
10   and value of maintaining a skilled and engaged workforce, where all employees are customer
11   focused and enjoy working for the utility. Operational planning focuses on balancing cost effective
12   spending with practical operational requirements and finding efficiencies when possible. Example
13   of efficiencies include co-operating with other LDCs (UCS, CHEC), outsourcing and automation.
14
15                                               Table 20: Operation Costs Table
                                   Board
                                                 2014                2015            2016          2017          2018              2019
                                  Approved
     Operations                     $532,044      $491,400            $548,540        $654,295      $673,867      $679,413          $715,973
     Maintenance                    $416,132      $412,259            $451,578        $476,273      $414,737      $473,074          $449,790
     Billing and Collecting         $534,260      $559,556            $601,150        $547,188      $573,154      $597,617          $632,867
     Community Relations             $17,800            $578                $758        $9,700        $4,161         $12,765         $11,485
     Administrative and General     $655,026      $744,411            $721,094        $844,735      $929,202     $1,141,995    $1,164,070
     Total                         $2,155,262   $2,208,203           $2,323,119      $2,532,191    $2,595,121    $2,904,865    $2,974,186

16   %Change (year over year)                           2.5%                5.2%            9.0%          2.5%        11.9%               2.4%

17
18   Operational spending in a smaller LDC such as NOTL Hydro is necessarily uneven as relatively
19   small changes can have a pronounced effect; especially if you have several in one year. The
20   large increase in costs from 2017 to 2018 is due to less time spend on capital work by senior
21   management, the new Utilismart contract, maternity leaves and a new VP Operations. The
22   increase in cost per customer, as per the table below, reflects these changes.
23
24                                           Table 21: Operational Costs per Customer
                                                               2014           2015          2016      2017       2018          2019
      NOTL Hydro                                               258            262           277       276        307           308
      Ontario average                                          271            275           278       -          -             -

25   NOTL Hydro does not currently have any plans for new staff and will be absorbing the changes
26   made in 2018 for a few years. The operating cost per customer is therefore expected to be stable
27   for the next few years.
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 1
 2                   Chart 22: Operational Costs per Customer Provincial Comparison

 3
 4
 5   Personnel
 6   NOTL Hydro currently employs 18 full time employees. The only part-time employee is the safety
 7   consultant. Twelve of the staff are part of the union, IBEW Local 636, while six are management.
 8
 9   NOTL Hydro’s comparatively small staff allows a team atmosphere to be developed. The
10   increased communication, mutual support and customer focus that derives from this team spirit
11   cannot be underestimated. The team spirit is maintained by continuing investment in staff,
12   monthly all team meetings and, most important of all, the general recognition that we are all equal
13   as human beings.
14
15   The continuing investment in staff and technology has resulted in a consistently improving
16   financial performance as measured by the number of customers per staff. This can be seen in the
17   following chart. Due to the small size of NOTL Hydro as an LDC it is important to look at the
18   overall trend rather than the variations from year to year.
19
20   No new hires are currently planned for 2018 and 2019. Hires subsequent to 2019 will be
21   determined based on workload and growth.
22
23   One of the challenges with a small company like NOTL Hydro is succession planning. It is not
24   possible to have a back-up for every position in the company. It is also in the company’s best
Niagara-on-the-Lake Hydro Inc.
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1   interest to promote from within when possible. NOTL Hydro has developed succession plans for
2   its mid-level management. Developing succession plans for the executive team is more
3   challenging. NOTL Hydro reviews these successions on a case-by-case basis with the long-term
4   goal being a mix on internal promotions and external hires.
5
6                                        Chart 23: Customers per Employee

                        Niagara-on-the-Lake Hydro Customers per Employee
     600

     550

     500

     450

     400

     350

     300

           Number of NOTL Hydro employees:
                          NOTL customers per employee            Ontario customers per employee
                          Linear (NOTL customers per employee)
7
8
Niagara-on-the-Lake Hydro Inc.
                                                                              EB-2018-0056| Business Plan
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                                                                                         Filed: August 2018

 1   Financial Performance
 2   NOTL Hydro’s past and future financial performance is summarized below.
 3
 4                                   Table 24: Financial Performance ($000’s)
                          2014           2015         2016        2017          2018            2019
                          (Actual)       (Actual)     (Actual)    (Actual)      (Application)   (Application)
      Distribution
      Revenues            4,878          5,003        5,332       5,338         5,502           6,047
      OM&A                2,238          2,342        2,474       2,617         2,940           3,009
      Depreciation        1,137          950          898         892           783             1,157
      Interest            381            490          512         476           416             392
      Net Income before
      Tax                 1,121          1,221        1,448       1,352         1,363           1,489
      Net Income after
      Tax                 1,114          714          1,009       1,384         1,197           1,308
      Return on Equity
      (Deemed capital)    10.85%         8.90%        7.44%       9.81%         9.00%           9.00%
 5
 6   In 2018, of the amortization of the excess revenue NOTL Hydro had earned between the time it
 7   extended the useful life of many of its assets under IFRS and the incorporation of this reduced
 8   expense in rate was completed. This had served to reduce other income with a corresponding
 9   reduction in depreciation. In addition, since 2015, contributed capital has been amortized to
10   revenue rather than net against depreciation. This also corresponds to the increase in
11   depreciation.
12
13   Interest is based on actual expected debt levels rather than on the deemed debt. The interest
14   expense will therefore be lower than that used in the rate application while the tax expense and
15   net income will be higher.
16
17   Return on Equity is shown based on a deemed capital structure. The actual return on equity will
18   be lower due to NOTL Hydro’s conservative capital structure. The deemed return on equity for
19   2017 is 9.81%, which is slightly above the Board Approved rate of return of 9.36%. Return on
20   equity will show more volatility than expected based on annual revenues and expenses due the
21   tax expense. For 2018 and 2019 the target return on equity will be the OEB allowed rate of 9.00%.
22
23   NOTL Hydro expects that financial performance will continue to improve. However, the
24   improvement will be limited to the increase in net assets as per the regulatory model. The increase
25   in net assets will be limited by NOTL Hydro’s goal of keeping low rates.
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